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“reasons recorded”

ReassessmentSection 148Section 14813,127 judgments

The decision most relied on for reasons recorded is Hindustan Lever Ltd. v. R.B. Wadkar (268 ITR 332), cited in 695 judgments on BharatTax.

Leading authorities on reasons recorded

Hindustan Lever Ltd. v. R.B. Wadkar
268 ITR 332 · 2004 · High Court
695
citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

T.S. Balaram ITO v. Volkart Bros.
82 ITR 50 · 1971 · Supreme Court
382
citing judgments

A mistake apparent from the record under Section 154 must be an obvious and patent error, not one that requires a long and elaborate process of reasoning or where two opinions are conceivable. Rectification under Section 154 is not permissible for re-examining issues already considered or requiring detailed re-computation.

CIT v. Orient Craft Ltd.
354 ITR 536 · 2013 · High Court
366
citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

222 Taxman 15 (Gujarat)(MAG.), Principal Commissioner of Income-tax-4 v. G & G Pharma India Ltd.
384 ITR 147 · 2016 · High Court
274
citing judgments

Reassessment proceedings are invalid if initiated based on documents already available on record without fresh tangible material, and if the sanction under section 151 is accorded mechanically, indicating non-application of mind.

M/s Sahara India (Farms) v. CIT & Anr.
300 ITR 403 · 2008 · Supreme Court
268
citing judgments

The requirement of statutory prior approval by a high-ranking authority, even if administrative, serves as an in-built protection against arbitrary exercise of power by the Assessing Officer. While such approval need not record elaborate reasoning, the approving authority has a heavy duty to ensure it is not an empty ritual, fulfilling its purpose of supervisory control.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

Pepsi Foods (P.) Ltd. v. Asstt. CIT
367 ITR 112 · 2014 · High Court
225
citing judgments

For assessments under Section 153C, a specific satisfaction note by the Assessing Officer of the person searched, recorded prior to initiating proceedings, is a jurisdictional prerequisite, rendering its absence void. The approval function under Section 153D is administrative and does not require elaborate reasoning.

Sarthak Securities Co. Pvt. Ltd. v. ITO
329 ITR 110 · 2010 · High Court
217
citing judgments

Reassessment proceedings under Section 147 are invalid if the Assessing Officer records satisfaction based on borrowed satisfaction or information without independently applying their mind and forming their own 'reason to believe' that income has escaped assessment. The AO must arrive at an independent conclusion, not merely act on a report from an investigation wing without due diligence.

Judgments citing reasons recorded

Dream Infrastructure, Rajkot vs. The Income Tax Officer, Ward - 1(1)(1), Rajkot

In the result, the appeal filed by the assessee is allowed

ITA 220/RJT/2025[2011-12]Status: DisposedITAT Rajkot04 Dec 2025AY 2011-12

Bench: Dr. Arjun Lal Sainiआयकर अपील सं./Ita No. 220/Rjt/2025 ("नधा"रण वष" / Assessment Year: 2011-12) Dream Infrastructure, Vs. Income Tax Officer, Mavdi Survey No. 358, B/H. Mavdi Ward-1(1)(1), Village, Kankot Road, Mavdi, Rajkot Rajkot-360004(Guj) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aahfd2565L (Assessee) (Respondent) Assessee By : Shri D.M. Rindani, Ar Respondent By : Shri Abhimanyu Singh Yadav, Sr. Dr Date Of Hearing : 22/09/2025 Date Of Pronouncement : 04/12/2025

For Appellant: Shri D.M. Rindani, ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr. DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 234ASection 271(1)(c)

response to the above notice, the assessee filed return of income, on 23.04.2018, declaring total income of Rs.1/-. The assessee further asked for reasons recorded for reopening the case. Accordingly, copy of reasons recorded was provided to the assessee. Further, notice u/s. 143(2) of the Act was issued ... consideration pertains to assessment year (A.Y._ 2011-12, however, the reasons were recorded by the Assessing Officer for assessment year (A.Y.) 2013-14, hence reasons recorded by ITA No.220/RJT/2025/AY.2011-12 Dream Infrastructure the assessing officer are invalid, therefore, reassessment proceedings initiated against the assessee, may be quashed. 10. On the other

Shri Ikbalbhai Jumabhai Khirani, Rajkot vs. The ITO Ward-1 (2) (1), Rajkot

ITA 843/RJT/2024[2018-19]Status: DisposedITAT Rajkot04 Dec 2025AY 2018-19

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Dheeraj Kumar Gupta, Ld. Sr. DR
Section 142(1)Section 144BSection 147Section 148Section 234ASection 250Section 270ASection 44A

other materials brought on record.Learned Counsel for the assessee submitted that Page 5 of 15 Shri Ikabalbhai Jumabhai Khirani vs. ITO the reasons recorded by the assesssing officer are defective and for that Ld. Counsel for the assessee took me through the reasons recorded by the assesssing officer, which ... placed at paper book page no.22 and stated that in the reasons recorded it is mentioned the terminology (sale by any person) which is a general observation which is not applicable to the assessee under consideration. Further, Ld. Counsel for the assessee took me through para no.5 of the reasons

ACIT, Circle 3, Lucknow vs. Anshuman Singh, Lucknow

In the result, the appeal of Revenue is allowed

ITA 342/LKW/2025[2017-18]Status: DisposedITAT Lucknow04 Dec 2025AY 2017-18
Section 139Section 142Section 142(1)Section 143Section 143(3)Section 144Section 147Section 148

erred in law and on facts of the case in quashing the assessment order 147 r.w.s.144 without appreciating the fact that in the reasons recorded by the assessing officer regarding escapement of income, clearly mention that the assessee's case is covered under the deeming provisions of Explanation ... framing the impugned reassessment order stating by para 2 of the Assessment Order that he has provide reasons for re-opening however neither the reasons recorded for re-opening nor copy of appropriate sanction taken from the competent authority was supplied to the appellant.\n\nGround No. 2:\nThat having

Nisha Fazal, Gautam Budh Nagar vs. ITO-4(3), Kanpur-01

In the result, appeal of the assessee is allowed

ITA 226/LKW/2024[2012-13]Status: DisposedITAT Lucknow04 Dec 2025AY 2012-13
Section 1Section 142(1)Section 147Section 148Section 271(1)(b)

beyond the time lime limit than therefore, the\nreopening of case is invalid and bad in law.\n4.\nBecause, the reasons recorded by the Id. ITO-1(5) and obtained\napproval Pr. CIT-1, at Kanpur and issued notice u/s 148 dated\n31/03/2019, and income tax department transferred ... Kanpur. Copy of sale deed are annexed herewith as\nAnnexure No. 10.\n8.\nThat the case was reopened and reason recorded by the Assessing\nOfficer -1(5), Kanpurdated 25.03.2019 after obtained approval from\nPr. CIT -1, Kanpur,and issued notice u/s 148 of the Income Tax Act,\n1961 dated

Principal Commissioner of Income Tax 2 Kolkata vs. M/S Royal Touch Fablon Private Limited

The appeal is dismissed

ITAT/132/2025HC Calcutta03 Dec 2025

Bench: HON'BLE JUSTICE RAJARSHI BHARADWAJ,HON'BLE JUSTICE UDAY KUMAR

Section 143(2)Section 147Section 148Section 68

account of unexplained cash credit U/s. 68 of the I.T. Act without considering the fact that income escaping assessment in reasons recorded has also been considered as unexplained and taken due cognizance of ? d) WHETHER in facts and in the circumstances of the case the Ld. Income Tax Appellate Tribunal ... were without jurisdiction for the reason that no addition was made in respect of the item of income referred to in the reasons recorded which according to the AO has escaped assessment. We have considered the facts carefully as placed before us and find that in this case

Balakumar Radhakrishna, Chennai vs. DCIT, Corporate Circle-5(1), Chennai

In the result, the appeal filed by the assessee is partly- allowed

ITA 2309/CHNY/2025[2014-15]Status: DisposedITAT Chennai03 Dec 2025AY 2014-15

Bench: Shri George George Kआयकर अपील सं./Ita No.: 2309/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15

For Appellant: Shri Arjun Raj, CAFor Respondent: Shri P. Krishna Kumar, JCIT
Section 143(3)Section 148Section 250

possession for issuance of notice u/s.148 of the Act after the completion of original assessment proceedings. The Ld.AR by referring to the reasons recorded for reopening the assessment submitted that it is clear no tangible new material has come to the possession of AO for issuance of notice ... response to the notice, assessee filed return of income disclosed the income disclosed in the original return filed and had sought for the reasons recorded vide his letter dated 21.11.2019. The reasons recorded for reopening the assessment was, furnished by the AO vide his letter dated 05.12.2019. The reasons recorded

Imran Ahmad, Moradabad, Uttar Pradesh vs. Income Tax Officer, Moradabad

Appeal is partly allowed

ITA 3490/DEL/2025[2013-2014]Status: DisposedITAT Delhi03 Dec 2025AY 2013-2014
Section 139Section 147Section 148

that there was live link between the information received by the AO and belief made that income chargeable to tax has escaped assessment. The reasons recorded by AO have been found on the basis of tangible material and with application of mind. At the stage of formation of belief

Viraj Software Pvt. Ltd., Delhi vs. ITO, Ward-26(4), Delhi

Appeal is dismissed

ITA 1084/DEL/2025[2012-13]Status: DisposedITAT Delhi03 Dec 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2012-13 M/S. Viraj Software Pvt. Vs. Income Tax Officer, Ltd., Ward-26(4), 28, Raja Garden, New Delhi New Delhi Pan: Aaccv5229M (Appellant) (Respondent) Assessee By None Department By Ms. Ankush Kalra, Sr. Dr

Section 142(1)Section 143(1)Section 143(2)Section 144Section 147Section 148Section 68Section 69C

notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included in the reasons recorded under sub-section (2) of section 148." 8.1.2 Hence, considering the above legal provisions before initiating action under section ... opening of the assessment, and after filing of the return it is the right of the assessee to obtain the copy of the reasons recorded by the AO. Once this request is made the AO is bound to provide the copy of the reasons recorded within a reasonable time

DCIT Central Circle-1, Noida vs. Nivedan Fin-Invest Lease Ltd., Delhi

In the result, Revenue’s appeal is dismissed

ITA 1713/DEL/2023[2015-16]Status: DisposedITAT Delhi03 Dec 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2015-16

Section 115BSection 133(6)Section 147Section 148Section 151Section 69A

assessee preferred appeal before the learned CIT(Appeals) who deleted the addition, inter alia, by observing as under: 4 “6.6 In the reasons recorded for reopening and in the assessment order Ld AO states that Sh. Vikas Bhagat, director of Airwill Group of Companies, in the statement given ... statement, Sh. Manoj Kumar Chaudhary has provided the total unaccounted interest and amount of loan taken from various lenders In the reasons recorded there is a list of 8 persons, of such lenders, whose name details of contact person, address, PAN, Contact number. amount of interest paid @12% per annum

D.C.I.T., CC - 3(1), Kolkata vs. Glix Securities Private Limited, Kolkata

In the result, the CO of the assessee and Revenue’s appeal are dismissed

ITA 1291/KOL/2025[2011-12]Status: DisposedITAT Kolkata02 Dec 2025AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shri Pardip Kumar Choubey, Jm Dcit Glix Securities Private Limited 110, Shanti Pally, 1St Floor 1, Grant Lane, Aayakar Bhawan Poorva, Vs. Kolkata-700012, West Bengal Kolkata-700107, West Bengal (Appellant) (Respondent) Pan No. Aabcg1844J Co No. 66/Kol/2025 (Arising In Ita No. 1291/Kol/2025 For A.Y. 2011-12) Dcit Glix Securities Private Limited 110, Shanti Pally, 1St Floor 1, Grant Lane, Aayakar Bhawan Poorva, Vs. Kolkata-700012, West Bengal Kolkata-700107, West Bengal (Appellant) (Respondent) Assessee By : Shri Manish Tiwari, Ar Revenue By : Shri P.N. Barnwal, Dr Date Of Hearing: 14.10.2025 Date Of Pronouncement: 02.12.2025

For Appellant: Shri Manish Tiwari, ARFor Respondent: Shri P.N. Barnwal, DR
Section 131Section 143(2)Section 147Section 148Section 68

Thus, in the given facts and circumstances, were hold that there is no infirmity in the order of the Ld.CIT-A. " 7. For the reasons recorded above, no question of law muchless substantial questions arises in this appeal. It stands meritless and accordingly dismissed. 07. Considering the facts

Qilin Supporters, Tirupur vs. ITO, Ward-2(4), Tirupur

In the result, the appeal filed by the assessee is allowed

ITA 1275/CHNY/2025[2016-17]Status: DisposedITAT Chennai02 Dec 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1275/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Qilin Supporters Vs. The Income Tax Officer, 11, Kasturibai Street, Udumalpet, Ward 2(4), Tiruppur 642 126. Tirupur. [Pan: Aaafq2944D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. M. Subashri, Addl. Cit (Virtual) सुनवाई की तारीख/ Date Of Hearing : 20.11.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 07.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Ld. Ar Shri S. Sridhar, Advocate Drew Our Attention To The Additional Ground Raised Vide Letter Dated 22.09.2025 & Submits That The Issue Of Questioning The Reopening As Legal Ground Can Be Raised At Any 2

For Appellant: Shri S. Sridhar, Advocate (Erode)For Respondent: Ms. M. Subashri, Addl. CIT (Virtual)
Section 143(2)Section 148Section 43CSection 50C

escaped assessment. Further, he drew our attention to the notice dated 29.09.2020 issued under section 143(2) of the Act seeking information as per reasons recorded for reopening under section 50C of the Act. The ld. AR argued that though the Assessing Officer reopened the assessment under section ... assessment order. He vehemently argued that the reassessment is not maintainable for making no addition 3 I.T.A. No.1275/Chny/25 in terms of the reasons recorded for reopening and placed reliance in the case of DCIT v. Govinda Rajulu Srinivasan for AY 2014-15 in ITA No. 1245/Chny/2025 vide order dated

ACIT-19(1), Mumbai vs. Parul Diamond, Mumbai

In the result, appeal and cross-objection filed by the revenue as well as the assessee respectively, stands dismissed

ITA 6992/MUM/2024[2007-08]Status: DisposedITAT Mumbai02 Dec 2025AY 2007-08

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 37Section 68

original return filed on 20/11/2010 in response to the notice u/s 148 of the Act. The assessee requested the Ld. AO to furnish reasons recorded before issuance of notice u/s 148 of the Act. The Ld. AO on 19/06/2014 5 I.T.A. No. 6992/Mum/2024 C.O. No. 53/Mum/2025 provided the reasons recorded ... scanned and reproduced as under:- The assesse thereafter vide letter dated 02/02/2015 raised various objections challenging the reopening of the assessment based on the reasons recorded which was rejected by the Ld. AO vide order dated 12/02/2015. 6 I.T.A. No. 6992/Mum/2024 C.O. No. 53/Mum/2025 2.2. The Ld. AO thereafter called

Urvashi Girishbhai Lal, Rajkot vs. ITO WD 1(2)(1), Rajkot

In the result, appeal filed by the assessee, is allowed

ITA 466/RJT/2025[2013-14]Status: DisposedITAT Rajkot01 Dec 2025AY 2013-14

Bench: Dr. Arjun Lal Saini

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(2)Section 144BSection 147Section 148Section 234ASection 250Section 271(1)(c)Section 68

reopened based on incorrect facts.The re-opening is based on the basis of the information received from DDIT (Inv.), Ahmedabad. As per the reasons recorded for re-opening, the main reason is stated as under: Page 4 of 7 Urvashi Girishbhai Lal, "That the assessee has booked bogus long term ... sale of shares during the year. The relevant extract of the return of income filed is as under: Therefore, the very foundation of reasons recorded for re-opening of the assessment that the assessee has booked bogus LTCG is incorrect. The reasons Page 5 of 7 Urvashi Girishbhai Lal, recorded

Aahana Sales Private Limited, Ahmedabad vs. PCIT(Central), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 878/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Nov 2025AY 2018-19

Bench: S/Shri Sanjay Garg & Makarand V.Mahadeokarasstt.Year : 2018-19 Aahana Sales Private Limited Pr.Cit(Central) 3, Bhavya Enclave Vs. Ahmedabad. Vidhya Vihar Society Usmanpura Ahmedabad. Pan : Aajca 1231 B (Applicant) (Responent) Assessee By : Shri Vivek Chavda, Ar Revenue By : Shri R.P. Rastogi, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 11/11/2025 घोषणा क" तारीख /Date Of Pronouncement: 28 /11/2025 आदेश/O R D E R Per Makarand V.Mahadeokar, Am:

For Appellant: Shri Vivek Chavda, ARFor Respondent: Shri R.P. Rastogi, CIT-DR
Section 143(1)Section 144Section 147Section 148Section 263Section 263(1)

character of a complete scrutiny and that the Assessing Officer was empowered to examine all issues arising from the assessment records, irrespective of the reasons recorded. Relying upon Explanation 2(a) to section 263(1) and a series of judicial authorities the PCIT concluded that the assessment order was erroneous ... reopening. 2.2 The Ld. PCIT has failed to appreciate that when the AO was having limited scope of assessment u/s 147 confined to the reasons recorded, it cannot be said that the AO has committed error in not verifying the alleged expenditures. 2.3 That in the facts and circumstances

M/S. H & F Games Pvt. Ltd., Bellandur, Marathahalli, Bengaluru vs. Deputy Commissioner of Income Tax - Central Circle - 1(2), Bengaluru

In the result, the appeal of the assessee for AY 2013-14 & AY 2014-15

ITA 1552/BANG/2025[2014-15]Status: DisposedITAT Bangalore28 Nov 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Balram Rao, AdvFor Respondent: Shri. Balusamy N, Jt. CIT(DR)(ITAT), Bangalore
Section 133(6)Section 147Section 148Section 234A

opposed to law and circumstances of the case 1. The notice issued u/s.148 is bad in law as the A.O. has not supplied Reasons recorded for re- opening of Assessment along with notice u/s.148. 2. The Assessment order passed u/s.148 is bad in law as the A.O. has not recorded ... opposed to law and circumstances of the case 1. The notice issued u/s.148 is bad in law as the A.O. has not supplied Reasons recorded for re- opening of Assessment along with notice u/s.148. 2. The Assessment order passed u/s.148 is bad in law as the A.O. has not recorded

M/S. H & F Games Pvt. Ltd., Bellandur vs. Deputy Commissioner of Income Tax - Central Circle - 1(2), Bengaluru

In the result, the appeal of the assessee for AY 2013-14 & AY 2014-15

ITA 1551/BANG/2025[2013-14]Status: DisposedITAT Bangalore28 Nov 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Balram Rao, AdvFor Respondent: Shri. Balusamy N, Jt. CIT(DR)(ITAT), Bangalore
Section 133(6)Section 147Section 148Section 234A

opposed to law and circumstances of the case 1. The notice issued u/s.148 is bad in law as the A.O. has not supplied Reasons recorded for re- opening of Assessment along with notice u/s.148. 2. The Assessment order passed u/s.148 is bad in law as the A.O. has not recorded ... opposed to law and circumstances of the case 1. The notice issued u/s.148 is bad in law as the A.O. has not supplied Reasons recorded for re- opening of Assessment along with notice u/s.148. 2. The Assessment order passed u/s.148 is bad in law as the A.O. has not recorded

Income Tax Officer, Mumbai vs. Wasundhara Vinay Joshi, Powai

In the result, the appeal of the Revenue is dismissed

ITA 5907/MUM/2025[2016-17]Status: DisposedITAT Mumbai28 Nov 2025AY 2016-17

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri Vikram Singh Yadavassessment Year : 2016-17 Income Tax Officer, Wasundhara Vinay Joshi, Room No. 830D, C-111, Sunrise Apts., 8Th Floor, Vs. Raheja Vihar, Kautilya Bhavan, Chandivali Farm Road, Bandra Kurla Complex, Chandivali, Bandra East, Mumbai-400007. Mumbai-400051. Pan : Afjpk0008C (Appellant) (Respondent) For Assessee : Shri Chetan Shinde For Revenue : Shri G.J. Ninawe, Sr.Dr Date Of Hearing : 26-11-2025 Date Of Pronouncement : 28-11-2025 O R D E R Per Vikram Singh Yadav, A.M : This Is An Appeal Filed By The Revenue Against The Order Of The Learned Commissioner Of Income Tax (Appeals)-National Faceless Appeal Centre (Nfac), Delhi [„Ld.Cit(A)‟], Dated 18-08-2025, Pertaining To Assessment Year (Ay) 2016-17, Wherein The Revenue Has Taken The Following Grounds Of Appeal: "1) Whether On The Facts & In The Circumstances Of The Case & In Law, The Ld. Cit(A) Has Erred In Deleting The Addition Of Rs. 1,76,860/- U/S 69A Of The Income Tax Act, 1961 Without Considering The Fact That The Assessee Fail To Furnish Demat Account & Copy Of Bank Statement.

For Appellant: Shri Chetan ShindeFor Respondent: Shri G.J. Ninawe, Sr.DR
Section 139Section 147Section 148Section 69A

under Section 69A of the Income-tax Act, 1961, treating the same as unexplained money. The reasons recorded by the assessing officer, however, are cryptic and internally inconsistent. Vide page 3 of the assessment order, it is noted that the AO has not even undertaken the basic exercise of perusing

Agarwal Holdings Private Limited, Mumbai vs. Principal Commissioner of Income Tax -1, Mumbai

In the result, the appeal by the assessee is dismissed

ITA 3389/MUM/2025[2022-23]Status: DisposedITAT Mumbai28 Nov 2025AY 2022-23

Bench: Shri Sandeep Singh Karhailshri Girish Agrawalagarwal Holdings Private Ltd. 211, 2Nd Floor Atlanta Arcade, Marol Church Road Marol, Andheri (East) Mumbai - 400059 ............... Appellant Pan: Aauca5094K V/S Principal Commissioner Of Income Tax, Mumbai-1 ……………… Respondent Room No.330, 3Rd Floor, Aayakar Bhavan, Maharishi Karve Road, Mumbai Assessee By : Shri Ashok Bansal Revenue By : Shri Rajesh Kumar Yadav, Cit-Dr

For Appellant: Shri Ashok BansalFor Respondent: Shri Rajesh Kumar Yadav, CIT-DR
Section 111ASection 142(1)Section 143(3)Section 144BSection 263

than 12 months is a business income or capital gains in the hands of the assessee was not examined by the AO and the reasons recorded for the complete scrutiny as well as the notice issued under section 142(1) of the Act are also not on this issue. Thus

Nipin Steels Private Limited, Delhi vs. Income Tax Officer, Delhi

The appeal of the assessee is allowed and the impugned addition is quashed

ITA 3923/DEL/2025[2011-12]Status: DisposedITAT Delhi28 Nov 2025AY 2011-12

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2011-12 Nipin Steels Private Ltd., Vs Ito, Y-4-A-C, Loha Mandi, Ward 18(3), Naraina Industrial Estate, Delhi Delhi – 110 028. Pan:Aaccm2046H (Appellants) (Respondents) Assessee By : Shri Ashwini Kumar & Shri Ankur Aggarwal, Ca Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 16.09.2025 Date Of Pronouncement : 28.11.2025

For Appellant: Shri Ashwini Kumar &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)Section 147Section 148

independent enquiries on third parties. 2.1 In reference to impugned reopening reasons it was submitted that in the instant case a review of the reasons recorded for resorting to the reassessment proceedings and issue of notice u/s 148 of the Act would reveal that the same 2 are merely based ... otherwise the transaction under scan are demonstrated to be sham. 4. Appreciating the material on record and after taking into consideration the copy of reasons recorded under Section 148 of the Act available at page 54 – 56 of the paper book, we find that the AO in para

Ess Gee Trendz Private Limited, Peeragarhi vs. Assistant Commissioner of Income Tax, Rohtak

In the result, the appeals of the Assessee in ITA Nos

ITA 3014/DEL/2025[2016-17]Status: DisposedITAT Delhi28 Nov 2025AY 2016-17

Bench: Shri M. Balaganesh & Ms Madhumita Roy

For Appellant: Shri Anuj Tiwari, CAFor Respondent: Shri Om Parkash, Sr. DR
Section 143(3)Section 144Section 147Section 148Section 149Section 151Section 68

proviso to section 147 of the Act. 5. That the notice issued under section 148 dated 31.03.2021 is invalid and without jurisdiction, as the reasons recorded for reopening were not provided to the assessee either along with the notice or thereafter, thereby violating the principles of natural justice 6. That ... Assessee was reopened under Section 147 of the Act. Notice under Section 148 of the Act dated 31-03-2021 was duly issued. The reasons recorded for reopening the assessment are as under:- “1. The assessee flied its return income of Rs. 14701230/- for the year under Act, 1961 dated